Recent content by rb91134

I didn't find any definitive answer backed by case law/evidence/IRS instructions etc. So I haven't decided what I'll be doing yet but will most likely be putting in UAE instead of leaving it blank.

Thanks Forester. I am a dual citizen of the Commonwealth of Dominica, and Turkey. Any specific recommendations in this case?

Thanks Sol - appreciate your response. I will check out Zen and 3S.Money. We used to have an a/c with Hellenic Bank many years ago. But that got shut down when Cyprus was going through some banking issues if I remember correctly. Tried with RCB Bank after that but they simply sat on our...

I need to open a business bank account with an EMI for a Cyprus ecommerce company (nothing high risk). 3 things worth mentioning: 1. The company has a resident Cyprus director but the UBO (me) is a non-EEA national. 2. We need USD denominated accounts and USD denominated incoming and outgoing...

So I guess this involves incorporating a Cyprus non-resident company (in order to have 0% corporate tax) but since a Cyprus non-resident company will have to state where it will be taxed while filing its tax returns, this company will require a director who is a resident of a tax-free country...

OK, thanks. Do you have any thoughts regarding the best jurisdiction for the new spin-off holding company based on the criteria I mentioned in the original post?

I see - thanks for the clarification. Makes sense. However, do you think a spin-off (as opposed to a transfer of assets) is necessary in this case from an exemption from taxation perspective given that the transfer of assets will happen this financial year and the CT laws for my UAE co only kick...

Can you elaborate how the spin-off would work exactly? Did you mean that I should just incorporate a new company and have the UAE co transfer ownership of the sites to the new company for no monetary consideration whatsoever? No - I am not.

Thanks for your response. I am a digital nomad and spend no more than 2-3 months in a particular country in a year. And those countries tend to vary every year. I actually don't want to liquidate/dissolve the UAE company - I want to keep it going for various reasons. What I'd like to do is to...

Thanks for your response. My concern actually is not whether the IRS shares those forms with my home country or any other country, but rather, making sure that I am not providing any inaccurate information in the form to them. The question that the form asks is: "Country(ies) under whose laws...

My current situation: - I am a perpetual traveler - My original country of nationality has a strict "days test" for determining tax residency - doesn't have tests like "habitual abode" or "center of life" - I own a UAE freezone company (which currently acts as my holding company) and US LLC...

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I am a perpetual traveler with a U.S. LLC and my original home country has a strict days test (and nothing else) to determine tax residency. Does anyone know whether the fields 1n ("Country(ies) under whose laws the reporting corporation files an income tax return as a resident") and 4e...

According to Cabinet Decision No. 100 of 2023 released on 3 November 2023: "The scope of qualifying income is extended to include the amount of qualifying income derived from the ownership or exploitation of qualifying intellectual property, excluding expressly any marketing related intellectual...

//I know someone who closed their freezone company (FZC, I think), and they were only allowed to do it after signing a declaration that they would personally take on all the liabilities of the company.// Interesting. The main thing I am trying to protect myself from is any future lawsuit from a...